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Cal. Super. - 2nd Dist.September 5, 2018

Electronically FILED] OO 0 NN NN nn BA W N = N N N N N N N N N N mm e m e m e m e m e m e m p m e m pe c o NI O N Ln B A W N Y = DO V X N N N R E L ND = O Khail A. Parris (SBN 307296) Eric N. Wilson (SBN 291815) Jason L. Maves (SBN 321526) PARRIS LAW FIRM 43364 10th Street West Lancaster, California 93534 Telephone: (661) 949-2595 Facsimile: (661) 949-7524 Attorneys for Plaintiffs ROCIO SABBAH, ARIELLA SABAH, a minor by and through her Guardian ad Litem ROCIO SABBAH, ELIJAH SABBAH, a minor by and through her Guardian ad Litem ROCIO SABBAH, Plaintiffs, V. ) ) ) ) ) ) ) ) COUNTY OF LOS ANGELES, LOS ) ANGELES COUNTY SHERIFF'S ) DEPARTMENT, DEAN SPRINGS, ALICIA ) ELIAS, MARIO ELIAS, JASON ANDREW ) MCGEE, and DOES 1 through 50, inclusive, ) ) ) ) ) ) ) Defendants. by Superior Court of California, County of Los Angeles on 02/04/2020 03:11 PM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Aquino,Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES Case No.: BC720891 [Assigned for all purposes to the Honorable Marc C. Gross, Dept. 3] PLAINTIFF’S REPLY IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORY SET ONE; DECLARATION OF JASON L. MAVES Date: Februarv 11. 2020 Time: 10:00am Dent. 3 Reservation No.: 305685285149 Complaint filed: September 5, 2018 Trial Date: March 5, 2020 PLAINTIFFS’ REPLY IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORY SET ONE OO 0 NN NN nn BA W N = N N ND N N N N N N E m e m e m em e m em e m e m c o NI O N Ln B A W N Y = DO V X N N N R E L ND = O SUMMARY OF REPLY Plaintiff's motion illustrates why Defendant McGee's responses should not include numerous preliminary objections, a paragraph of boilerplate objections, and blanket assertions of privacy and privilege, to which each response is "subject." However, Defendant’s opposition ignores the law provided in Plaintiffs’ motion, and points to his “substantive response,” hoping that this court will ignore his inability to argue that the identification of items like photos and videos are not protected under privilege. Defendant also offers no law in support his contention that he is entitled to assert objections in the attempt to “preserve the objection.” Plaintiff has offered legal authority that these claims are not accurate; however, Defendant simply ignores it. Further, Defendant served supplemental responses after the filing of the present motion and now asks this court to make the motion moot. Defendant disregards the fact that his further response remain evasive and presents the same preliminary and boilplate objections. Defendant’s supplemental responses do not address the concerns Plaintiff laid out in her meet and confer, nor her motion, and the only practical purpose for these supplemental responses is to force further meet and confers, and delay their substantive participation in the discovery process. This Court should Order Defendant to provide further responses that withdraw unnecessary objections, identify all photos and videos, and respond to each interrogatory in a code compliant manner as is illustrated in Plaintiffs’ motion. ARGUMENT IL. Defendant cannot serve bad-faith supplemental responses as a tactic to prevent Plaintiffs from obtaining a Court Order instructing Defendant to provide code-compliant responses. First, Defendant claims Plaintiff’s motion is moot because further, equally evasive responses were served on December 23, 2019. (Maves Decl., Ex. A.) This is not entirely accurate. Defendant may not use bad faith supplemental responses as a tactic to prevent Plaintiff from obtaining a Court Order instructing Defendant to provide code-compliant responses. Defendant cannot offer new objections in lieu of providing substantive responses and demand that a new motion to compel be filed. Plaintiff is entitled to review the supplemental responses and determine whether they are sufficient to withdraw the pending motion to compel. (See Sinaiko Healthcare Consulting, Inc. v. 1 PLAINTIFFS’ REPLY IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORY SET ONE OO 0 NN NN nn BA W N = N N ND N N N N N N E m e m e m em e m em e m e m c o NI O N Ln B A W N Y = DO V X N N N R E L ND = O Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 407 [explaining trial courts may grant a motion to compel even if the responding party serves responses after it has been served with the motion]; R.M. v. First Lutheran Church (Cal. Ct. App., Apr. 4, 2017, No. B266389) 2017 WL 1231383, at *4 [explaining parties do not have to “engage in meet and confer efforts in response to each iteration of supplemental responses its opponent files” as this would “incentivize piecemeal production, prolong discovery disputes, and raise litigation costs™].) A Court Order instructing Defendant to provide code-compliant responses is necessary given Defendant’s repeated misuse of the discovery process in order to delay production. Further, Defendant’s supplemental response are still not code compliant for the reasons below. a. Form Interrogatory 4.1: Defendant’s supplemental responses refuse to identify his insurance policy Defendant has supplemented his response to Form Interrogatory 4.1, but it still refuses to identify the insurance policy at the time of the collision. Identify means to state the kind of coverage, the insurance company, the insured, the policy number, the limits of coverage, whether there is a reservation of rights, and the identity of the custodian of the policy. Instead of responding to each subpart appropriately, Defendant provides a blanked statement saying, “he was insured as an employee for the County of Los Angeles. The County of Los Angeles is self-insured pursuant to Government Code §§ 989, 990, et seq., 990.2, and generally, County Ordinance, Title V, Chapter 5.32.” (Opp. at Ex. C [See p. 3:5-7.].) A code compliant response should be compelled. b. Form Interrogatory 15.1: Defendant’s supplemental responses remain evasive and do not respond to each affirmative defense individually, creating confusing and non- responsive answers Defendant has plead thirty-nine (39) entirely distinct affirmative defenses. For each of the affirmative defenses, Defendant must state the (a) facts, (b) witnesses, and (c) documents, pertaining to each defense. If Defendant has no facts, witnesses, or documents for their numerous affirmative defenses, at this time, it must so clearly state. Whether Defendant “is still investigating the subject incident” is of no consequence, as Form Interrogatory No. 15 asks for the facts, witnesses, and documents supporting each of Defendant’s affirmative defenses at the present time. Accordingly, the 2 PLAINTIFFS’ REPLY IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORY SET ONE OO 0 NN NN nn BA W N = N N ND N N N N N N E m e m e m em e m em e m e m c o NI O N Ln B A W N Y = DO V X N N N R E L ND = O Defendant must flesh out each affirmative defenses and each of the distinct sub-parts (a, b & ¢), and indicate whether there are any facts, witnesses, and documents supporting each defense presently. Anything less does not constitute a code-compliant response and will warrant the filing of a motion to compel. Here, Defendant’s supplemental response only offers a blanked response that never identifies which facts, witnesses, and documents correspond to each of its thirty-nine affirmative defenses. Further, Defendant has not deviated from his a cryptic and vague assertion that Decedent was “driving at an unsafe speed” and therefore “caused or contributed to his own death.” (Maves Decl., Ex. A [See p. 3:26-27.].) Defendant must be compelled to respond to each affirmative defense individually, provide facts, witness, and identify documents presently known that are applicable to each individual affirmative defense. (See generally Code Civ. Proc. § 2030.220.) Additionally, the response impermissibly includes preliminary objections, a one paragraph list of boilerplate objections, and also blanket assertions of privacy and privilege, to which each response is "subject." This is not permitted, as is further explained below, and should be removed if no information is being withheld. IL. Defendant does not refute that photographs and videos are not protected under the attorney-client privilege, but still avoids identifying video believed to be within his control Defendant also refuses to respond to 12.4 regarding the identification of photos and videos of the collision and surrounding events. Defendant's vehicle is believed to have a dash cam. Instead of identifying as much, Defendant partially responds and asserts blanket privilege objections. Defendant asserts attorney-client privilege, but 12.4 does not call for any protected information because it is simply asking Defendant to identify any evidence responsive to the request; it is not asking for production. Even if it was asking for production, photographs and videos are generally not protected. (See Greyhound Corp. v. Superior Court (1961) 56 Cal.2d 355; Suezaki v. Superior Court (1962) 58 Cal.2d 166.) Defendant’s opposition never refutes Plaintiff's assertion the law does not protect photographs and videos, however, they still maintain they can assert the objection without providing any legal reasoning. The court should not permit this. 3 PLAINTIFFS’ REPLY IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORY SET ONE OO 0 NN NN nn BA W N = N N ND N N N N N N E m e m e m em e m em e m e m c o NI O N Ln B A W N Y = DO V X N N N R E L ND = O III. Defendant provides no law to support his claim that he can insert objections to “preserve the objection” Plaintiff also included in her motion to compel that each set of responses impermissibly includes preliminary objections, one paragraph of boilerplate objections, and also blanket assertions of privacy and privilege, to which each response is "subject." Plaintiffs asked Defendant to remove privilege and privacy objections to which no responsive information or documents are being withheld. (See Bihun v. AT&T Information Systems (1993) 13 Cal. App.4th 976, 991 fn.5 [objecting when no documents exist is “bad faith.”]; Korea Data Systems Co. Ltd. v. Superior Court (1997) 51 Cal. App.4th 1513, 1516 [“Boilerplate” objections are sanctionable].) Defendant has failed to present law that supports this tactic and thus this court should order Defendant to produce further responses without boilplate objections. CONCLUSION For the foregoing reasons, Plaintiffs respectfully requests that the court grant Plaintiffs’ motion to compel further responses to their Form Interrogatory, Set One. The Court should also award Plaintiffs $1,566.95 to compensate them for the costs and attorneys’ fees incurred in bringing this motion. DATED: February 4, 2020 PARRIS LAW FIRM 7 KTail A. Parris Eric N. Wilson Jason L. Maves Attorneys for Plaintiff 4 PLAINTIFFS’ REPLY IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORY SET ONE OO 0 NN NN nn BA W N = N N ND N N N N N N E m e m e m em e m em e m e m c o NI O N Ln B A W N Y = DO V X N N N R E L ND = O DECLARATION OF JASON L. MAVES I, Jason L. Maves, declare as follows: 1. I am an attorney duly licensed to practice before all courts of the State of California and I am an associate with the Parris Law Firm, attorneys of record for Plaintiff. I have personal knowledge of the following. 2. Attached hereto as Exhibit “A” is a true and correct copy of Defendant’s supplemental responses to Plaintiffs’ Form Interrogatory, Set One. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 4th day of February, 2020, at Lancaster, California. eT Jason LL. Maves 13 DECLARATION OF JASON LL. MAVES EXHIBIT “A” eo 0 N S n t A W N NN N N N N N N m m e m em e m p m e m em e d A U i RA W N = o C N N N R W N = O 27 28 COLLINS COLLINS MUIR + STEWART. Brian K. Stewart, Esq. (State Bar No. 126412) Allison R. Bracy, Esq. (State Bar No. 235927) Lauren F. Guccione, Esq. (State Bar No. 311856) COLLINS COLLINS MUIR +STEWART LLP 1100 El Centro Street South Pasadena, CA 91030 (626) 243-1100 -- FAX (626) 243-1111 Exempt from Payment of Filing Fee Pursuant to Govt. Code § 6103. Attorneys for Defendants COUNTY OF LOS ANGELES and DEPUTY JASON MCGEE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES ROCIO SABBAH, ARIELLA SABBAH, a ) CASE NO. BC720891 minor by and through her Guardian ad Litem ) [Assigned to Judge Marc C. Gross, Dept. 3] ROCIO SABBAH, ELIJAH SABBAH, a minor ) by and through her Guardian ad Litem ROCIO ) DEFENDANT JASON MCGEE’S SABBAH, ) SUPPLEMENTALRESPONSES TO FORM INTERROGATORIES- GENERAL, SET Plaintiffs, ONE Vs. COUNTY OF LOS ANGELES, LOS ANGELES COUNTY SHERIFF DEPARTMENT, DEAN SPRINGS, ALICIA ELIAS, MARIO ELIAS, JASON ANDREW MCGEE, and DOES 1 through 50, inclusive, Complaint Filed: 9/5/18 Trial Date: 3/5/20 Defendants. COUNTY OF LOS ANGELES, Cross-complainant, VS. DEAN SPRINGS, ALICIA ELIAS, MARIO ELIAS and ROES 1 through 100, inclusive Cross-defendants. N e N e N e N e N e N e N e N e N e N e N e N e N e N e N e N e N N N N N N N N 21661 1 JASON MCGEE SUPPLEMENTAL RESPONSES TO FORM INTERROGATORIES eo 0 N S n t A W N NN N N N N N N m m e m em e m p m e m em e d A U i RA W N = o C N N N R W N = O 27 28 COLLINS COLLINS MUIR + STEWART. PROPOUNDING PARTY: PLAINTIFF, ROCIO SABBAH RESPONDING PARTY: DEFENDANT, JASON MCGEE SET NO.: ONE (SUPPLEMENTAL) TO PLAINTIFF AND TO HER ATTORNEYS OF RECORD HEREIN: DEFENDANT, JASON MCGEE (hereinafter "Responding Party") hereby provides responses to Form Interrogatories (Set One) propounded by PLAINTIFF, ROCIO SABBAH, as follows: PRELIMINARY STATEMENT This responding party has not completed discovery in this action and has not completed preparation for trial. All of the responses contained herein are based only upon such information and documents as are presently available to and specifically known by this responding party. The following responses are given without prejudice to responding party's right to produce evidence of any subsequently-discovered fact(s) at the time of trial. These responses are made in a good faith effort to supply as much factual information and as much specification of legal contentions as is presently known, but should in no way be to the prejudice of the responding party in relation to further discovery. RESPONSES TO FORM INTERROGATORIES FORM INTERROGATORY NO. 4.1: At the time of the INCIDENT, was there in effect any policy of insurance through which you were or might be insured in any manner (for example, primary, pro-rata, or excess liability coverage or medical expense coverage) for the damages, claims, or actions that have arisen out of the INCIDENT? If so, for each policy state: @) the kind of coverage; (b) the name and ADDRESS of the insurance company; ©) the name, ADDRESS, and telephone number of each named insured; d) the policy number; (e) the limits of coverage for each type of coverage contained in the policy; 21661 2 JASON MCGEE SUPPLEMENTAL RESPONSES TO FORM INTERROGATORIES eo 0 N S n t A W N NN N N N N N N m m e m em e m p m e m em e d A U i RA W N = o C N N N R W N = O 27 28 COLLINS COLLINS MUIR + STEWART. ® whether any reservation of rights or controversy or coverage dispute exists between you and the insurance company; and (2) the name, ADDRESS, and telephone number of the custodian of the policy. RESPONSE TO FORM INTERROGATORY NO. 4.1: Responding Party is informed and believes that he was insured as an employee for the County of Los Angeles. The County of Los Angeles is self-insured pursuant to Government Code §§ 989, 990, et seq., 990.2, and generally, County Ordinance, Title V, Chapter 5.32. FORM INTERROGATORY NO. 15.1: Identify each denial of a material allegation and each special or affirmative defense in your pleadings and for each: @) state all facts upon which you base the denial or special or affirmative defense; (b) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and (©) identify all DOCUMENTS and other tangible things which support your denial or special or affirmative defense, and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. RESPONSE TO FORM INTERROGATORY NO. 15.1: Objection: Responding Party objects to this interrogatory on the grounds that it calls for information that is protected by the attorney work product doctrine and attorney-client privilege. Responding Party further objects to the extent this request seeks confidential information or that protected by the official information and litigation privileges. Further, it seeks a legal conclusion and expert testimony. Also, it is premature as Responding Party has only recently begun its discovery and is still investigating the subject incident. Code of Civil Procedure section 431.30 states that a general denial is a sufficient response to an unverified complaint. Without waiving the foregoing objections, Responding Party responds as follows: Responding Party is informed and believes that Decedent Isaac Abraham Sabbah caused or contributed to his own death by driving at an unsafe speed and colliding with Mr. Springs’s vehicle. 21661 3 JASON MCGEE SUPPLEMENTAL RESPONSES TO FORM INTERROGATORIES eo 0 N S n t A W N NN N N N N N N m m e m em e m p m e m em e d A U i RA W N = o C N N N R W N = O 27 28 COLLINS COLLINS MUIR + STEWART. According to the traffic collision report, Sabbah was driving at an unsafe speed in violation of Vehicle Code section 22350. Additionally, Responding Party is informed and believes that other parties, including California Department of Transportation, Defendant Dean Springs and Alicia Elias caused or contributed to Plaintiffs’ injuries. Deputy McGee was operating his vehicle with due care and, notwithstanding his exercise of due care, the collision could not have been avoided on account of the other parties’ negligent conduct. Neither County Defendant are liable to Plaintiffs. Individuals with knowledge to support these contentions include: Responding Party; Deputy Tyler Robison, who can be contacted through counsel; Isaac Abraham Sabbah; Alicia Elias, 8756 De Soto Ave. #201, Canoga Park, CA, 91304, (818) 564-2126; Lopez Gilberto, Los Angeles County Jail inmate; Frank Gutierrez, Los Angeles County Jail inmate; Dean Springs, 1826 N. Frederick, Burbank, CA 91505, (516) 524-0152; California Highway Patrol (“CHP”) Officers Romero, T. Bomar, S. Farber, C. Hitchcock, H. Castaneda, M. Pielock, J. Crain, C. Watson, S. Suazo, M. Terry; CHP MCS-I, A. Byrum, CHP Engineer N. Eskander, and CHP Sergeant N. Parsons, CHP Sergeant M. Little. Responsive documents include: Traffic Collision Report, Report Numbers 9575-2017-17716, 9575-2017-17717, 9575-2017-17718; MAIT Report, No. 9575-2017-17718. DATED: December 23, 2019 COLLINS COLLINS MUIR 4 STEWART LLP By: LAUREN GUCCIONE BRIAN K. STEWART ALLISON R. BRACY Attorneys for Defendants COUNTY OF LOS ANGELES and JASON MCGEE 21661 4 JASON MCGEE SUPPLEMENTAL RESPONSES TO FORM INTERROGATORIES eo 0 N S n t A W N NN N N N N N N m m e m em e m p m e m em e d A U i RA W N = o C N N N R W N = O 27 28 COLLINS COLLINS MUIR + STEWART. PROOF OF SERVICE (CCP §§ 1013(a) and 2015.5; FRCP 5) State of California, ) ) ss. County of Los Angeles. ) I am employed in the County of Los Angeles. I am over the age of 18 and not a party to the within action. My business address is 1100 El Centro Street, South Pasadena, California 91030. On this date, I served the foregoing document described as DEFENDANT JASON MCGEE’S SUPPLEMENTAL RESPONSES TO FORM INTERROGATORIES- GENERAL, SET ONE on the interested parties in this action by placing same in a sealed envelope, addressed as follows: SEE ATTACHED SERVICE LIST P<] (BY MAIL) - I caused such envelope(s) with postage thereon fully prepaid to be placed in the United States mail in South Pasadena, California to be served on the parties as indicated on the attached service list. I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at South Pasadena, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. [ ] BY CERTIFIED MAIL) - I caused such envelope(s) with postage thereon fully prepaid via Certified Mail Return Receipt Requested to be placed in the United States Mail in South Pasadena, California. UJ BY EXPRESS MAIL OR ANOTHER METHOD OF DELIVERY PROVIDING FOR OVERNIGHT DELIVERY X (BY ELECTRONIC FILING AND/OR SERVICE) - I served a true copy, with all exhibits, electronically on designated recipients listed on the attached Service List. [ ] FEDERAL EXPRESS - I caused the envelope to be delivered to an authorized courier or driver authorized to receive documents with delivery fees provided for. [1 BY FACSIMILE) - I caused the above-described document(s) to be transmitted to the offices of the interested parties at the facsimile number(s) indicated on the attached Service List and the activity report(s) generated by facsimile number (626) 243-1111 indicated all pages were transmitted. [1 BY PERSONAL SERVICE) - I caused such envelope(s) to be delivered by hand to the office(s) of the addressee(s). Executed on December 23, 2019 at South Pasadena, California. [XI (STATE) - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. [1 (FEDERAL) - I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. oA Le a Silvia Perez siperez@ccmslaw.com 21661 5 JASON MCGEE SUPPLEMENTAL RESPONSES TO FORM INTERROGATORIES ROCIO SABBAH v. COUNTY OF LOS ANGELES 1 Los Angeles County Superior Court - Case No. BC720891 Our File No. 21661 2 SERVICE LIST 3 Alexander R. Wheeler, Esq. Mario Elias Jonathan W. Douglass, Esq. 20919 Parthenia St, #28 4 Ellery S. Gordon, Esq. Canoga Park, CA 91304 PARRIS LAW FIRM (818) 262-6620 5 43364 10th Street West MElias @metroemail.com Lancaster, CA 93534 DEFENDANT/CROSS-DEFENDANT 6 (661) 949-2595 - FAX: (661) 949-7524 awheeler @parrislawyers.com jdouglass @parrislawyers.com 7 egordon @parrislawyers.com ATTORNEYS FOR PLAINTIFFS 8 cc: TeamKhail @parrislawyers.com 9 Yancy Robertson yrobertson @parrislawyers.com J. Pat Ferraris, Esq. 10 Edward E. Dollar, Esq. HOMAN & STONE 11 12 North Fifth Street Redlands, CA 92373 12 (909) 307-9380 - FAX: (909) 793-0210 jpferraris@homan-stone.com edollar@homan-stone.com 13 ATTORNEYS FOR DEFENDANT, DEAN SPRINGS 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COLLINS COLLINS || 21661 MUIR + STEWART. 6 JASON MCGEE SUPPLEMENTAL RESPONSES TO FORM INTERROGATORIES OO 00 JI AN Un BA W N N S N N ND N N N N N = e m e m e m e m e m e m e m e m 0 NN O N Ln BR A W N D = OO VD N N N R E W D = Oo PROOF OF SERVICE 10 evise /88 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is: 43364 10™ Street West, Lancaster, California 93534. On 2/4/20, 1 served the foregoing document described as PLAINTIFFS’ REPLY IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORY SET ONE AND REQUEST FOR SANCTIONS; DECLARATION OF JASON L. MAVES by placing the [__] original / [Xx__] a true copy thereof enclosed in sealed envelopes addressed as follows: See attached Service List [x] BY GSO/OVERNIGHT MAIL as follows: I placed such envelope in a GSO Mailer addressed to the above party or parties at the above address(es), with delivery fees fully pre-paid for next-business-day delivery, and delivered it to a GSO pick-up driver before 4:00 p.m. on the stated date. Executed on 2/4/20 at Lancaster, California. [ X] I declare under penalty of perjury under the laws of the State of California that the above is true and correct. ) 7) 117A Esmeralda Vera OO 00 JI AN Un BA W N N N N N N N N N N E m e m e m e m e m e m em e m 0 NN O N Ln BR A W N D = OO VD N N N R E W D = Oo SERVICE LIST Sabbah v. County of Los Angelest, et al. Brian K. Stewart, Esq. /Attorneys for Defendants COUNTY OF Allison R. Bracy, Esq. LOS ANGELES (erroneously sued as Collins, Collins, Muir + Stewart, LLLP LOS ANGELES COUNTY SHERIFF 1100 EI Centro Street DEPARTMENT and JASON ANDREW South Pasadena, CA 91030 MCGEE Telephone: (626) 243-1100 Facsimile: (626) 243-1111 J Pat Ferraris, Esq, /Attorneys for Defendant Dean Springs HOMAN & STONE 12 North Fifth Street Redlands, CA 92373